Statler v. George A. Ray Mfg. Co. - 195 N.Y. 478, 88 N.E. 1063 (1909)

Rule:

In the case of an article of an inherently dangerous nature, a manufacturer may become liable for a negligent construction which, when added to the inherent character of the appliance, makes it imminently dangerous, and causes or contributes to a resulting injury not necessarily incident to the use of such an article if properly constructed, but naturally following from a defective construction.

Facts:

Appellant George A. Ray Manufacturing Company manufactured coffee urns for use in hotels. One of the urns manufactured by appellant was sold to a hotel where respondent was the president. The urn exploded, resulting in severe injury to the respondent and death to another. Respondent instituted a personal injury action against appellant. During trial, respondent was allowed to testify on his financial interest in the hotel, and on the amount of money he spent after the accident. A letter alleging that the urn was defective was also admitted as evidence. The trial court entered a jury verdict in favor of respondent. The Appellate Division of the Supreme Court in the Fourth Judicial Department (New York) affirmed. Appellant sought further review. 

Issue:

On the basis of the evidence presented, was the verdict in favor of respondent properly awarded? 

Answer:

No.

Conclusion:

The Court reversed the decision of the lower courts, noting that the trial court improperly admitted evidence, constituting reversible error. Specifically, the court held that: 1) evidence of the victim's financial interest in the hotel was inadmissible to demonstrate how his business suffered from his sickness, because it was an element of damages not pleaded; 2) evidence of money the victim expended on trips claimed necessary for the benefit of his health after the accident was inadmissible without accompanying evidence of the medical necessity for such trips; and 3) a damaging letter from a former officer of the company alleging that the urn was defective was made in his personal capacity, and not as an officer of the company, and was incompetent, prejudicial and inadmissible.